Privacy Policy

Zorya is committed to the protection of personal data and the privacy of Users, professionals, partners, suppliers, prospective clients, and third parties. In compliance with the Federal Law on Protection of Personal Data Held by Private Parties (the “Law”) and its Regulations, Zorya hereby makes this Privacy Notice (the “Privacy Notice”) available to you so that you may exercise your rights of access, rectification, cancellation, and objection (the “ARCO Rights”).

Capitalized terms used in this Privacy Notice and not otherwise defined herein shall have the meaning assigned to them in the Platform’s Terms and Conditions.

Controller and Address

Zorya Technologies, S.A. de C.V. (“Zorya”), with registered address at Lago Ginebra 86 – A608, Col. Cuauhtémoc Pensil, Miguel Hidalgo Borough, Mexico City, Mexico, C.P. 11490, is responsible for the collection, storage, use, processing, transfer and/or disposal of personal data.

PERSONAL DATA COLLECTED

You may browse our website and the Platform without providing personal data; however, through the Platform and/or the website you may voluntarily provide your data in order to register a Request for Account.

The personal data we may collect falls within the following categories:

• Identification and contact data: full name, corporate name and company or organization (if applicable), country, address, date of birth, telephone number, email address, image, official identification, description of the project for which the Services on the Platform will be required, and any additional information the User provides to Zorya.

For purposes of verifying the legal representation of a legal entity, Zorya may collect name, date of birth, contact telephone number, official identification, and any other information and documentation required under applicable law in order to verify identity, legal capacity, and authority.

• Employment data: position, address, email address, and telephone number.

• Demographic data: including information related to the geographic location of the device used on the Platform.

• Billing data: banking institution to which charges will be made, tax address, federal taxpayer registration number or its equivalent under applicable law.

• Financial data: bank account information, payment methods (if applicable).

Zorya may collect any personal data of any nature voluntarily provided by the data subject through any means, whether printed, digital (electronic), optical, or any other known or future technology, as well as any personal information contained in documentation provided to Zorya regarding the processing of personal data.

The User grants consent for Zorya to collect copies of documents and/or supporting materials related to the personal data specified in this section, as determined by Zorya.

Information Entered for Use of the Platform

Any information that constitutes personal data and that the User voluntarily enters into the Platform, including information derived from the use of the Platform and/or provided by the User for purposes of the Services.

The User must refrain from entering sensitive personal data on the Platform and/or in any of the Services.

When Do We Collect Information?

Zorya collects information: (i) when the User registers a Request for Account through the Platform, (ii) when contact information is entered on our website – www.zorya.com.mx –, (iii) when data is provided via email, SMS messages and/or any other electronic, optical, audiovisual, known or future means, and (iv) when data is provided directly and personally to Zorya.

Social Media

Our website may provide the option to redirect you to social media services such as Facebook, Instagram, Twitter, LinkedIn, among others. Please note that Zorya does not control these social media services and does not establish privacy settings or rules regarding how your personal data will be used on such websites. We strongly recommend that, prior to entering your data on such platforms, you review their respective privacy notices to understand how your personal data will be handled. Accordingly, Zorya shall not be responsible for the processing of personal data that you voluntarily submit on such platforms.

Purpose of the Use of Personal Data

Zorya may use your personal data for various purposes, depending on the specific circumstances under which it was collected:

• To verify the User’s identity.
• To verify the identity, legal personality, and legal capacity of a legal representative of a legal entity.
• To respond to questions and comments.
• To provide customer support regarding any Platform functionality and improve service when responding to customer service requests.
• To maintain contact.
• To contact you via SMS, phone call, or email with information about products, offers, promotions, and account-related information.
• To request ratings and reviews of our Services.
• To verify the User’s identity in connection with a Request for Account for use of the Platform and Services.
• To create a username and password account to access the Services on the Platform in accordance with the Terms and Conditions.
• To personalize account features.
• For invoicing purposes, if requested by the User.
• To generate statistics and market analysis in order to update the Platform and Services.
• To pursue legal actions deemed necessary by Zorya for the proper defense of its interests.
• To manage the legal relationship between Zorya and the User in accordance with the Services, the Platform, and the Terms and Conditions.
• To comply with applicable laws and regulatory requirements and respond to competent authorities.
• To protect and/or defend Zorya’s rights, property, and confidential information.
• To maintain and safeguard the security of the Platform, our website, and Users.

Transfer of Personal Data

You authorize Zorya to transfer your personal data to third parties in the following cases:

I. Controlled companies, subsidiaries, affiliates under common control with Zorya, parent companies, or any other company within Zorya’s corporate group.

II. Competent authorities to safeguard public interest or for the administration of justice, including for the recognition, exercise, or defense of legal claims.

III. Information related to the User’s credit or debit card may be transmitted to Adyen and/or PayPal, as applicable, in order for them to process payments (if applicable) requested through the Platform, in accordance with their own privacy policies.

IV. In any other case expressly provided by the Law.

Mechanisms to Request the Non-Use of Your Personal Data

If you disagree with any of the terms set forth in this Privacy Notice and do not wish your personal data to be processed for some or all of the stated purposes, you may express your refusal by sending an email to: legal@zorya.mx.

Rights Regarding Your Personal Data

As the data subject, you have the right to Access the personal data we hold about you, as well as to request Rectification, Cancellation, or Objection – ARCO Rights – in accordance with the Law. You may also revoke or limit the consent previously granted for the processing of your personal data. Please note that revocation of consent will result in Zorya being unable to continue providing the Services, and you will no longer be able to use the Platform, thereby terminating your relationship with Zorya.

You may exercise these rights by submitting a request in accordance with the Law to: legal@zorya.mx or at the following address: Lago Ginebra 86 – A608, Col. Cuauhtémoc Pensil, Miguel Hidalgo Borough, Mexico City, Mexico, C.P. 11490.

Your request must indicate which personal data you wish to rectify, cancel, or review, as well as the purpose for which it was originally provided. The request must generally comply with the requirements set forth in Article 29 of the Law.

Cookie Policy

We inform each User that we use cookies and similar storage technologies (“Cookies”) on the Platform. What are Cookies? – Cookies are small text files stored in the browser of each User’s device to retain certain information or image files such as pixels. Each time you access the Platform from the same device, the information stored in the Cookies is transmitted back to the Platform. Through the stored and returned information, the website recognizes that you have previously accessed it. Zorya uses this information to optimally design and display the Platform according to your preferences.

Consent to the use of Cookies – By accessing, browsing, and/or entering information on the Platform, you acknowledge and accept the use of Cookies. Categories of Cookies – The Cookies we may use depending on their purpose and function include: (i) performance cookies, (ii) functional cookies, (iii) advertising cookies, (iv) preference cookies, (v) security cookies, (vi) process cookies, (vii) session state cookies, (viii) analytics cookies, (ix) first-party and/or third-party cookies, (x) persistent and session cookies, (xi) technical, personalization, and analytical cookies. Disabling or deleting Cookies – The User may configure the browser used to access the Platform to prevent Cookies from being stored and/or to request confirmation each time Cookies are enabled. Users may also delete Cookies at their discretion. Each browser has different functions and configuration options; therefore, you should review your browser settings accordingly. Please note that disabling Cookies may result in limited functionality of the Platform.

Changes to the Privacy Notice

This Privacy Notice may be modified and/or updated from time to time. Any such changes will be communicated through our website www.zorya.com.mx.

Consent

By visiting our website, registering on the Platform, submitting a Request for Account, or interacting with our Services, you consent to the processing of your personal data in accordance with this Privacy Notice.

Last Update February, 2026.

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